Debra Snell, President
12562 Rough and Ready Highway
Grass Valley, CA 95945
(530) 273-1005 snell
Dan Dugan, Secretary
290 Napoleon St. Studio E
San Francisco, CA 94124
(415) 821-9776 dan
Scott M. Kendall, PLANS’ Attorney
8788 Elk Grove Blvd. Bldg. 1 Suite I
Elk Grove, CA 95624
(916) 685-7700 scottkendall



The U.S. District Court, Eastern District of California, has scheduled a trial starting date of March 19, 2001 for the lawsuit of People for Legal and Nonsectarian Schools, Inc. (PLANS) against two Northern California school districts. PLANS, an all-volunteer whistle-blowing group, is suing the districts over their operation of “Waldorf” schools. PLANS contends that tax-funded Waldorf schools are inextricably entangled with “Anthroposophy,” a cult-like religious sect, violating the Establishment Clause of the Constitution. The trial will be held in the Federal Courthouse in Sacramento, California.


PLANS filed its lawsuit in Sacramento on February 11, 1998, naming as defendants the Sacramento Unified School District, which operates a “Waldorf Method” magnet school, and the Twin Ridges Elementary School District, which has established several “Waldorf-inspired” charter schools. Discovery of evidence and depositions have been completed.

On September 24, 1999, United States District Judge the Honorable Frank C. Damrell, Jr., rejected the defendants’ motion for summary judgment. Later, on December 17 of last year, Judge Damrell allowed the schools to make a pre-trial appeal to the higher court on the issue of standing.

Judge Damrell had affirmed PLANS’ standing when he rejected the schools’ motion for summary judgment, but he allowed the districts to appeal that issue to the Ninth Circuit Court of Appeals. If the appeals court hadn’t backed up PLANS’ standing, there would be no point in having a trial. April 30, 2000, The Ninth Circuit Court of Appeals said “The petition for permission to appeal pursuant to 28 U.S.C.  1292(b) is denied.” This cleared the way for the new trial date to be set.

PLANS contends that public Waldorf schools are intrinsically and inseparably based upon a New Age occultic religion called Anthroposophy. Public Waldorf school curriculum decisions and teacher training are based on Anthroposophy’s spiritually based child development model. Publicly funded use and reliance upon the doctrines of Anthroposophy impermissibly endorses that religion in violation of the United States and California constitutions. In the discovery phase of the lawsuit, PLANS presented evidence that religious beliefs and practices of Anthroposophy were present in both schools.

Here is an example from a teacher-training text purchased by the Sacramento public school:

“Before the moment of earthly conception, the yet-to-be-born soul approaches the Gate of Birth, and there views a tableau of the life to come. In previous times, souls would immediately descend after witnessing this picture of their karmically-determined future. In our time, in which the world has grown so materialistic and life has become so difficult, more and more souls hesitate for a moment, reluctant to face their destiny. When they do choose to incarnate, they are a little late, and cannot “mesh” their higher members with their lower bodies. So a moment of hesitation, a little lateness, leads to an incomplete intertwining of body and soul, and this in turn can be a prime factor in those learning difficulties and emotional problems that will appear in childhood.” [Schwartz, Eugene. The Waldorf Teacher’s Survival Guide. Fair Oaks, CA: Rudolf Steiner College Press, 1992, p. 23]

PLANS was organized in late 1995 by former Waldorf parents and teachers concerned about both private and public Waldorf schools. It is an unlikely coalition, uniting liberals and evangelical Christians, factions that disagree strongly on other topics. PLANS became a California non-profit corporation in July 1997. PLANS’ volunteer board includes two public school teachers, one of whom has received Waldorf teacher training, the president of a skeptical society, a retired Baptist pastor, the associate director of a Christian anti-cult ministry, and two former Waldorf parents. PLANS’ President, Debra Snell, was a director of a private Waldorf school and helped found a Waldorf charter school. For more information, please see the PLANS web site,

Scott M. Kendall, PLANS’ attorney, maintains a private practice in the Sacramento area of California. He focuses a substantial part of his practice on issues involving religious liberty. This litigation is financially supported by volunteer directors of PLANS, has received underwriting from the Pacific Justice Institute of Sacramento, CA, and donations from the members of PLANS. Mr. Kendall may be contacted for further information regarding this litigation.